Specific tariff heading prevails for capsule and tablet printing machine classified as other printing machinery.
An imported capsule and tablet printing machine operating by offset gravure process was treated as a printing machine for tariff purposes. Heading 84.34 was held inapplicable because it was confined to machinery connected with type-founding or type-setting and did not cover the machine's actual working method. Heading 84.59, being residuary, could not apply where a more specific heading covered the goods. Applying the rule that the most specific description prevails, the machine was classified under Heading 84.35 as other printing machinery, and the assessment was directed to be made accordingly.
Issues: Whether the imported capsule and tablet printing machine was classifiable under Heading 84.34, Heading 84.59, or Heading 84.35 of the Customs Tariff.
Analysis: The machine printed names or monograms on tablets, capsules and similar items by offset gravure process and was therefore a printing machine. Heading 84.34 was found inapplicable because it was confined to machinery connected with type-founding or type-setting and did not cover the imported machine's working method. Heading 84.59, being a residuary entry, could be used only if no other specific heading covered the goods. Applying the rule that the heading giving the most specific description must be preferred, the machine was held to fall under the specific heading for other printing machinery.
Conclusion: The item was not classifiable under Heading 84.34 or Heading 84.59 and was correctly classifiable under Heading 84.35.
Final Conclusion: The assessment was set aside and the imported machine was directed to be assessed under the specific printing-machinery heading.
Ratio Decidendi: For tariff classification, the heading giving the most specific description prevails over a general or residuary heading, and the actual working and use of the imported machine determine its proper classification.
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